G.R. No. 209983 - Belarso vs. Quality House, Inc.

Private respondent Quality House, Inc. (QHI) is engaged in the manufacturing and distribution of leather products.
Petitioner Evelina E. Belarso was hired on November 14, 1976, initially assigned to the belt department.
In 1986, she was transferred to the raw materials warehouse and, on December 7, 1987, promoted to Raw Materials Supervisor.
As supervisor, Belarso was responsible for receiving, storing, and dispensing raw materials critical to QHI’s operations.

On December 10, 2010, during a routine outgoing inspection and body frisking at the QHI gate, Belarso’s bag was inspected.
Lady Guard Lolita Salamanca discovered a belt buckle inside her bag, an item which lacked authorization for removal from the warehouse.
Belarso denied any knowledge of how the belt buckle came to be in her bag.
An incident report was promptly filed by L/G Salamanca, with Security Guard Richard Portodo and two employees, Reagan Amurao and Dennis Velasco, providing testimonial evidence.

On December 13, 2010, Belarso received a notice placing her under preventive suspension and demanding a written explanation within 48 hours regarding the incident.
Belarso submitted her explanation on December 15, 2010, denying the accusations and stressing her long-standing familiarity with the company’s inspection protocols.
On December 22, 2010, she requested a dialogue with QHI’s management, which was granted, leading to a conference on January 4, 2011.
The conference yielded a “Rule Violation Memo” issued on January 6, 2011, wherein management expressed dissatisfaction with her explanation.

Following the memo, Belarso’s employment was terminated effective January 7, 2011, on grounds of stealing company property and loss of trust and confidence.
Prior to the issue of the final investigative report, Belarso had already filed a complaint for illegal dismissal on January 5, 2011.
QHI maintained that her dismissal was for just cause, asserting that she violated company rules regarding carrying personal bags and stole company property, despite the availability of lockers for employees.

The Labor Arbiter (LA) ruled that Belarso was illegally dismissed, citing disbelief that an employee of her tenure would commit theft and noting the dubious timing and wording of affidavits by guards and coworkers.
The LA awarded backwages and separation pay totaling P593,653.85.
QHI appealed the LA ruling to the National Labor Relations Commission (NLRC).
The NLRC reversed the LA’s decision, finding that the evidence established a just cause for dismissal due to a loss of trust and confidence, particularly given Belarso’s supervisory role and her responsibility over company property.

Belarso filed a Motion for Reconsideration with the NLRC, which was denied.
On appeal, the Court of Appeals (CA) sustained the NLRC’s findings, emphasizing that the evidence (including the incident report, multiple affidavits, and company rule violation memo) clearly supported QHI’s claims.
Belarso’s defenses, including the argument of a planted belt buckle and the similarity of affidavits, were rejected.
The CA affirmed the NLRC decision and denied her petition for review, upholding the validity of her dismissal.

Whether there exists a just cause to terminate the petitioner from her employment based on the circumstances leading to the discovery of the belt buckle during a routine inspection.

The contention centers on whether Belarso’s actions adequately constituted an attempt to steal or misappropriate company property, thereby breaching the trust reposed in her as a supervisor.
The issue encompasses whether the presence of the belt buckle, despite the possibility of it being planted, suffices to justify termination.

Granting arguendo that the petitioner violated the company’s rules and regulations, whether the imposition of the penalty of dismissal is proper and warranted given the overall circumstances.

The petitioner argued that the disciplinary measure was excessive in light of her 34 years of service and the alleged implausibility of her involvement in theft.
The dispute also involves consideration of whether the similar wording and timing of the affidavits surrounding the incident detract from their probative value.